Bowen v. Commissioner of Social Security

CourtDistrict Court, W.D. Washington
DecidedMay 28, 2021
Docket3:20-cv-05454
StatusUnknown

This text of Bowen v. Commissioner of Social Security (Bowen v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bowen v. Commissioner of Social Security, (W.D. Wash. 2021).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 NIKKI B., 8 Plaintiff, CASE NO. C20-5454-BAT 9 v. ORDER AFFIRMING THE 10 COMMISSIONER’S FINAL DECISION COMMISSIONER OF SOCIAL SECURITY, AND DISMISSING THE CASE WITH 11 PREJUDICE Defendant. 12

13 Plaintiff appeals the denial of her applications for Supplemental Security Income and 14 Disability Insurance Benefits. In a prior order, the Court affirmed the ALJ’s evaluation of the 15 plaintiff’s testimony and medical evidence, and remanded on the questions of (1) whether there 16 is reliable evidence supporting a conclusion plaintiff could perform past relevant work and 17 (2) whether there are a significant number of other jobs in the national economy plaintiff could 18 perform. Tr. 3270–96. A new ALJ reconsidered the evidence and all aspects of the sequential 19 evaluation, discounted plaintiff’s testimony and the medical evidence for substantially the same 20 reasons as did the prior ALJ, and concluded (1) plaintiff had no past relevant work and (2) there 21 are significant number of jobs in the national economy that plaintiff can perform. Tr. 3157–74. 22 The Court AFFIRMS the Commissioner’s final decision and DISMISSES the case with 23 prejudice. 1 BACKGROUND 2 Plaintiff is currently 42 years old, has a GED, and has worked as an administrative 3 assistant, customer service representative, materials handler, and order entry technician. Tr. 206, 4 245. In 2011, she applied for benefits and eventually amended her alleged onset date of disability

5 to August 19, 2011. Tr. 31. The district court has remanded her case twice. 6 In 2016, the Court concluded that the ALJ committed harmful error by failing to discuss 7 the examining opinion of Dr. Raymond West, M.D., with respect to limiting plaintiff to working 8 “in a comfortable chair.” Tr. 1483. In all other respects, the Court affirmed the ALJ’s evaluation 9 of plaintiff’s testimony and the medical evidence. Tr. 1486–94. The Court remanded so that the 10 ALJ could reexamine residual functional capacity, the reviewing opinions of Dr. Norman Staley, 11 M.D., and Dr. Drew Stevick, M.D., and plaintiff’s testimony only as necessitated by further 12 consideration of Dr. West’s opinion. Tr. 1487, 1494. 13 In 2019, the Court found that the ALJ had provided specific and legitimate reasons for 14 discounting Dr. West’s opinion on sitting limitations, and affirmed the ALJ’s evaluation of the

15 opinions of Drs. Staley and Stevick, plaintiff’s testimony, and the medical evidence. Tr. 3273– 16 92. The Court concluded, however, that the ALJ committed harmful error: (1) at step four by 17 failing to ask the vocational expert (“VE”) to offer testimony regarding plaintiff’s past work in 18 relation to an RFC-consistent hypothetical and failing to identify support for the conclusion that 19 plaintiff could perform her past work as either actually or generally performed; and (2) at step 20 five by failing to address the VE’s qualification in testimony regarding the impact of a walking 21 restriction on certain jobs and whether that qualification resulted in a smaller number of jobs 22 fitting the hypothetical. Tr. 3292–95. The Court remanded so the ALJ could address (1) whether 23 there is reliable evidence supporting a conclusion plaintiff could perform past relevant work; and 1 (2) whether there are a significant number of jobs in the national economy plaintiff could 2 perform. Tr. 3295. 3 Because the case had been remanded twice, the Appeals Council directed that the case be 4 assigned to a different ALJ. Tr. 3186. The new ALJ held a hearing in September 2019 and called

5 a VE to provide updated vocational testimony as directed by the remand order. Tr. 3188–3228. 6 In a January 2020 decision, the ALJ conducted the sequential analysis anew and determined that 7 plaintiff has the severe impairments of Crohn’s Disease, status post surgeries; and obesity. The 8 ALJ assessed an RFC of sedentary work with additional limitations. Tr. 3165. At step four, the 9 ALJ found that plaintiff has no past relevant work because she had not performed substantial 10 gainful activity long enough to meet the specific vocational preparation requirement. Tr. 3172. 11 At step five, the ALJ determined that based on RFC, all relevant factors, and VE testimony 12 plaintiff could perform the requirements of several jobs that exist in significant numbers in the 13 national economy. Tr. 3172–73. The ALJ therefore found plaintiff to be not disabled. Tr. 3173– 14 74. The ALJ’s decision is the Commissioner’s final decision.

15 DISCUSSION 16 The Court will reverse the ALJ’s decision only if it was not supported by substantial 17 evidence in the record as a whole or if the ALJ applied the wrong legal standard. Molina v. 18 Astrue, 674 F.3d 1104, 1110 (9th Cir. 2012). The ALJ’s decision may not be reversed on account 19 of an error that is harmless. Id. at 1111. Where the evidence is susceptible to more than one 20 rational interpretation, the Court must uphold the Commissioner’s interpretation. Thomas v. 21 Barnhart, 278 F.3d 947, 954 (9th Cir. 2002). 22 Although the scope of the remand of this Court’s 2019 order directed the ALJ to revisit 23 only steps four and five of the sequential analysis, it is not this portion of the ALJ’s 2020 1 decision that plaintiff challenges. Plaintiff instead argues that the ALJ assessed an incorrect RFC 2 and harmfully erred at step five by discounting the plaintiff’s testimony and medical evidence for 3 substantially the same reasons affirmed by this Court in its 2016 and 2019 decisions. Dkt. 28, at 4 2. The Court finds that plaintiff has failed to demonstrate that the ALJ’s decision was

5 unsupported by substantial evidence or applied the wrong legal standard. 6 1. Plaintiff’s Testimony 7 Plaintiff argues that the ALJ erred by failing to adopt her symptom testimony in toto. 8 Dkt. 28, at 9–17. The Court disagrees. 9 This Court previously found the ALJ’s adverse credibility determination to be supported 10 by substantial evidence and free from harmful error. Tr. 3274–82. The Commissioner argues that 11 plaintiff should therefore be barred from rearguing this question under the law of the case 12 doctrine. Dkt. 29, at 3; see Stacy v. Colvin, 82 F.3d 563, 567 (9th Cir. 2016). The Court declines 13 to apply the law of the case doctrine here given its inconsistency with the Commissioner’s 14 institutional position, represented in the 2020 ALJ decision, to accept additional medical

15 evidence and testimony, hold a new hearing, and reassess RFC and all sequential steps. 16 Nonetheless, the Court’s prior decisions are detailed and persuasive. As the ALJ accurately 17 observed, plaintiff’s symptom allegations are not substantially different from the allegations 18 made earlier and none of the “new” evidence presented since the last remand referred to a 19 different time period or indicated more severe impairments. Tr. 3168. Moreover, plaintiff argues 20 that her symptom testimony should be adopted based entirely on consistency with medical 21 evidence already evaluated and discounted in prior orders. See Dkt. 28, at 9–12 (referring 22 specifically to limitations supported by the opinions of Drs. West, Liu, Peterson, and Gaffield 23 and broadly to “all” medical evidence). 1 The ALJ discounted plaintiff’s symptom testimony because (1) plaintiff engaged in 2 activities that demonstrated she functioned better than alleged; (2) the medical records showed 3 her symptoms and limitations were not as severe as alleged; and (3) plaintiff’s non-compliance 4 with treatment undermined her symptom testimony. Tr. 3165–68. The Court has twice detailed

5 why these reasons are clear and convincing. Tr.

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Related

Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)
United States v. Harold M. Newcomb
6 F.3d 1129 (Sixth Circuit, 1993)

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Bowen v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bowen-v-commissioner-of-social-security-wawd-2021.